July 13 th , 2015 Great Scott Property Services Inc. Attn: Stanley R. Scott III 7215 Bedlington Road Miami Lakes, FL. 33014 stan@principalrealty.net

To:

Federal Aviation Administration

U.S. DEPARTMENT OF TRANSPORTATION

DOCKET MANAGEMENT SYSTEM 1200 NEW JERSEY AVE., SE WASHINGTON, DC 20590

FILED WITH www.regulations.gov

Re: Petitions for Exemption under Section 333 of th e FAA Reform Act and Part 11 of the Federal Aviation Regulations

To Whom in May Concern:

This application is being submitted on my own behal f.

Pursuant to Section 333 of the FAA Modernization an d Reform Act of 2012 (the Reform Act) and 14 C.F.R. Part 11, Great Scott Property Service s Inc., operator of a Small Unmanned Aircraft Systems (sUAS) equipped to conduct aerial photography and videography for the real estate industry, hereby applies for an exemption fr om the listed Federal Aviation Regulations (FARs) to allow commercial operation of its sUASs, so long as such operations are conducted

within and under the conditions outlined herein or as may be established by the FAA as required by Section 333.1

Great Scott Property Services Inc. requested exempt ion would permit the operation of sUAS under controlled and secure conditions that is: (i) limited, (ii) predetermined, (iii) subject to controlled access, and (iv) provide greater safety in connection with aircraft operations. As established by the exemptions already granted by th e FAA, approval of Great Scott Property Services Inc. exemption would enhance safety and fu lfill the FAA Administrator’s responsibilities to “...establish requirements for the safe operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform Act

14 C.F.R. Part 21

14 C.F.R. 45.23

14 C.F.R. 45.29

14 C.F.R 61.3

14 C.F.R. 61.23 14 C.F.R. 61.113(a) & (b) 14 C.F.R. 61.133(a) 14 C.F.R. 91.7(a)

14 C.F.R. 91.9 14 C.F.R. 91.109(a)

14 C.F.R. 91.11914 C.F.R. 91.121

14 C.F.R. 91.151(a)

14 C.F.R. 91.203 14 CFR Subpart E (91.401-91.417)

Applicant seeks an exemption from the following rul es: . 14 C.F.R Part 21, 14 C.F.R 45.23, 14 C.F.R. 45.29 , 14 C.F.R. 61.3, 14 C.F.R. 61.23, 14 C.F.R. 1.113(a) & (b), 14. C.F.R. 61.133(a), 14 C.F.R. 91. 7(a), 14 C.F.R. 91.9, 14 C.F.R. 91.109(a), 14 C.F.R. 91.119, 14 C.F.R. 91.121, 14 C.F.R. 91.151 ( a), 14 C.F.R. 91.203, 14 CFR Subpart E (91.401-91.417) to operate commercially a small unm anned vehicle (55 lbs or less) for the purposes of real estate photography and videography

.

Upon receipt of the exemption, I shall obtain a Cer tificate of Authorization (COA) from the FAA Air Traffic Organization prior to conduction operat ion(s) in the NAS. The DJI Phantom 2 will never be flown in the flight path of manned aircraf t.

AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The vehicle to be used will be the DJI Phantom 2. The operating limitations proposed by Great Scott Property Services Inc. provide for at least a n equivalent or higher level of safety because operations further enhance safety of aerial image c ollection using conventional aircraft.

The limitations and conditions include:

1. The sUASs will weigh less than 55 pounds. 2. Flights will be operated within line of sight (L OS) of a pilot and/or observer. 3. Maximum flight time for each operational flight will be no more than 30 minutes. Flights will be terminated at no less than 25% battery powe r reserve should that occur prior to

the 30 minute limit 4. Pre-flight inspection would be checking batter c ondition/level in both the transmitter and UAS. A check for power lines, antennas and other o verhead objects will be identified before flying. Wind conditions would also be monit ored before flying. 5. Stanley Scott will be Pilot in Command (PIC) wit h over 50 hours of flight time with the DJI Phantom 2. Testing, updating and programming t he DJI Phantom 2 would be done on a monthly schedule. 6. I am a citizen in good standing with no arrests or felonies. I am in good health and have

a sound mind. I am a Realtor in South Florida. 7. The intended use of the DJI Phantom 2 is to expa nd my independent contracting business by offering aerial photography to Realtors and to provide my clients with the best possible marketing available in South Florida. UAS aerial photography is a relatively new industry and entering the market at this time will provide me with a competitive edge to my Real Estate counterparts

8. If the UAS loses communications with the remote controller or loses GPS signal, the UAS will have the capability to return to a pre-det ermined location within a designated location and land autonomously.

Thank you for your attention. Best Regards,

Stanley R. Scott IIIANNEX A

EXEMPTION REQUEST AND EQUIVALENT LEVEL OF SAFETY SH OWINGS UNDER

APPLICABLE RULES SUBJECT TO EXEMPTION

Stanley R. Scott III requests an exemption from the following regulations as well as any additional regulations that may technically apply t o the operation of the DJI Phantom 2:

14 C.F.R. Part 21, Subpart H: Airworthiness Certifi cates 14 CFR § 91.203

Sections 91.203 requires all civil aircraft to have a certificate of airworthiness. Part 21, Subpart H, entitled Airworthiness Certificates, establishes the procedural requirements for the issuance of airworthiness certificates as required by FAR § 91.203(a). Given the light weight and the limited operating area with its use, it is unnecess ary to go through the certificate of airworthiness process under part 21 Subpart H in order to achieve or exceed current safety levels.

The Federal Aviation Act and Section 333 of the Ref orm Act both authorize the FAA to exempt aircraft from the requirement for an airworthiness certificate, upon consideration of the size, weight, speed, operational capability, and the prox imity to airports and populated areas of the UAS involved. The UAV, operated without an airwort hiness certificate, under the conditions proposed in the exemption, will be at least as safe , or safer, than a conventional aircraft with an

airworthiness certificate.

14 C.F.R. § 45.23 & 14 C.F.R. § 45.29: Display of m arks; size of marks

These regulations provide that each aircraft must d isplay “N” and the aircraft’s registration number in letters at least 3 inches high. The airc raft must display the word “Experimental” in letters at least 2 inches high near the entrance to the cabin, cockpit, or pilot station. Given the small size of the DJI Phantom 2, this requirement i s impossible to match.

14 C.F.R. §61.23: Medical certificates: Requirement and duration

Regulations provide that a person:

1. Must hold a first-class medical certificate:

• When exercising the pilot-in-command privileges of an airline transport pilot certificate;

• When exercising the second-in-command privileges o f an airline transport pilot certificate in a flag or supplemental operation in part 121 of this chapter that requires three or more pilots; or

• When serving as a required pilot flight crewmember in an operation conducted under part 121 of this chapter if the pilot has rea ched his or her 60 th birthday

2. Must hold at least a second class medical certif icate when exercising:

• Second-in-command privileges of an airline transpo rt pilot certificate in part 121 of this chapter (other than operations specified in paragraph (a)(1)(ii of this section); or

• Privileges of a commercial pilot certificateGiven the size, build, limited flight area, and the return to home autopilot flight termination

system features on the UAV, Stanley Scott believes that a person with a valid driver’s license can produce an equivalent level of safety.

14 C.F.R. § 61.3: Requirements for certificates, ra tings and authorizations 14 C.F.R. § 61.113(a) & (b); 61.133(a): Private Pil ot Privileges and Limitations; Pilot in Command; Commercial Pilot Privileges and Limitation s

Regulation provides that no person may serve as a r equired pilot flight crewmember of a civil aircraft of the United States, unless that person:

(1) Has a pilot certificate or special purpose pilo t authorization issued under this part in that person’s physical possession or readily accessible in the aircraft when exercising the privileges of that pilot certificate or authorizati on. However, when the aircraft is operated within a foreign country, a pilot license issued by that country may be used. The regulation provides also that no person that holds a private pilot certificate may act as pilot in command of an aircraft for compensation or hire. Subparagraph (b) allows a private pilot to act as p ilot in command of an aircraft in connection with any business or employment if:

1. The flight is only incidental to that business o r employment 2. The aircraft does not carry passengers or proper ty for compensation or hire

Stanley Scott proposes that operators of the UAV sh ould not be required to hold a commercial or private pilot certification. The equivalent lev el of safety will be achieved by having an operator trained UAV manufacturer, and using the in tegrated features of the aircraft to maintain a high level of safety at all times.

14 C.F.R § 91.7(a): Civil aircraft airworthiness

Subpart H, entitled Airworthiness Certificates, est ablishes the procedural requirements for the issuance of airworthiness certificates as required by FAR §91.203(a)(1). Given the size and limited operating area associated with the aircraft to be utilized by the applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of safety under Part 11

and Section 333 of the Reform Act. The Federal Avi ation Act (49 U.S.C. §44701 (f)) and

Section 333 of the Reform Act both authorize the FA A to exempt aircraft from the requirement for an airworthiness certificate, upon consideratio n of the size, weight, speed, operational capability, and the proximity to airports and popul ated areas of the particular UAS. In all cases, an analysis of these criteria demonstrates that the UAS operated without an airworthiness certificate, in the restricted environment and unde r the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed wing or rotorcraft) operating with an

airworthiness certificate without the restrictions and conditions proposed.

14 C.F.R. § 91.9: Civil aircraft flight manual, mar king, and placard requirements

The equivalent level of safety will be achieved by keeping a hard copy of the user manual in close proximity to the operator. The equivalent level of safety will be provided by having the UAV marked on its fuselage as required by §45.29 (f) where the pilot, observer an d others working with the UAV will see the identification of the UAS as "Experimental." The FA A has issued the following exemptions to this regulation to Exemptions Numbers 10700, 8738, 10167 and 10167A.14 C.F.R. § 91.109(a): Flight Instruction

The regulation provides that "No person may operate a civil aircraft that is being used for flight instruction unless that aircraft has fully function ing dual controls." The equivalent level of safety during the in-flight training will be achieved by the manufacturer or affiliate providing the training as described in th e manufacturer's training program and through the use of experienced and qualified instructors fa miliar with the UAV.

14 CFR § 91.119: Minimum Safe Altitudes

Section 91.119 establishes safe altitudes for opera tion of civil aircraft. The exemption requests authority to operate at altitudes up to 400 AGL, It will however be operated in a restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre obtained consent. The equivalent level of safety will be achieved given the size, weight, speed of the UAS as well as the location where it i s operated. No flight will be taken without the permission of the property owner or local officials . Compared to flight operations with aircraft weighing far more than those proposed herein and th e lack of flammable fuel, any risk associated with these operations is far less than t hose presently presented with conventional

aircraft.

14 CFR 91.121: Altimeter settings

This regulation requires each person operating an a ircraft to maintain cruising altitude by

reference to an altimeter that is set" ... to the e levation of the departure airport or an appropriate altimeter setting available before departure." As t he UAV may not have a barometric altimeter, but instead a GPS altitude read out, an exemption i s requested. An equivalent level of safety will be achieved by t he operator confirming the altitude of the

launch site shown on the GPS altitude indicator bef ore flight.

14 C.F.R. § 91.151(a): Fuel Requirements for Flight in VFR Conditions

The regulation provides that no person may begin a flight in an airplane under day-VFR

conditions unless there is enough fuel to fly to the first point of i ntended landing and to fly after that for at least 30 minutes. As the UAVs are electric-powered, this req uirement is inapplicable. In any event, given the contemplated operations, Stanley Scott believes that an equivalent level of safety is already achieved with the specific procedure preventing the UAVs accepting a take-off order if the battery level is below a given value. Moreover, the manufacturers have integrated low and critical battery level warnings and implemented a " return to home" action in these situations.

14 C.F.R. § 91.203 (a) & (b): Carrying Civil Aircra ft Certification and Registration

This regulation provides as follows: • No person may operate a civil aircraft unless it has an appropriate and current airworthiness

certificate. • No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight a uthorization issued under §91.715 are displayed at the cabin or cockpit entrance so that it is legi ble to passengers or crew. An equivalent level of safety will be achieved by k eeping these documents at the ground control point where the pilot flying the UAV will have imme diate access to them; to the extent they areapplicable to such UAV. The FAA has issued numerous exemptions to this regulation. A

representative sample of other exceptions includes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR Subpart E (91.401 - 91.417): Maintenance, Pr eventive Maintenance, and

Alterations

The regulation provides that the operator is primar ily responsible for maintaining the aircraft in an airworthy condition, including compliance with P arts 39 and 43. Paragraphs 91 A07 and 91 .409 require the aircraft to be "approved for retur n to service by a person authorized under 43.7" after maintenance and inspection. Section 91.409 re quires an annual inspection for the

issuance of an airworthiness certificate. Section 9 1 A 17 requires the owner or operator to keep records showing certain maintenance work that has b een accomplished by certificated mechanics, under Part 43, or licensed pilots and re cords of approval of the aircraft for return to

service. Stanley Scott proposes that the maintenance of the UAVs will be accomplished by the owner or the operator according to the manufacturer’s user m anual. Given that these section and Part 43 apply only to aircraft with an airworthiness certif icate, these sections will not apply to the applicant Maintenance will be accomplished by the o perator pursuant to the flight manual and operating handbook as referenced herein. An equival ent level of safety will be achieved because these small UAVs are very limited in size a nd will carry a small payload and operate only in restricted areas for limited periods of tim e. If mechanical issues arise the UAV can land immediately and will be operating from no higher th an 400 feet AGL. The operator will ensure

that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator i s the person most familiar with the aircraft

and best suited to maintain the aircraft in an airw orthy condition to provide the equivalent level of safety.